Case study

Developing a new governance process for complex policy management

Lead partnerMatt Neill

One of the world’s leading providers of payments infrastructure and messaging, launched a KYC Utility – KYC Registry – initially for Correspondent Banks in 2015. The core policy was developed and regularly reviewed with a KYC Registry User Group consisting of 18 Global Financial Institutions. BeyondFS was asked to review the existing process for managing policy updates to develop (and implement) a new process to simplify the complex engagement with multiple stakeholders, while delivering a significant update to the policy.

Industry segment
Banking Industry Vendor
Function
Compliance
Core capabilities
PMO / Programme Management, Policy

Key outcomes delivered

KYC / AML Policy refresh
Regulatory mapping (EU / US)
Effective working groups established across 18 Global Banks, Wolfsberg Group, ICC

Results

Key Achievement

global banks managed within a collaborative User Group

Timeframe

months to deliver major new policy enhancements

Enhancements

0 +

changes implemented to the baseline

Challenge

Collaboration with multiple stakeholders

Delivering and managing collaborative, yet structured, meetings with a large number of participants can be challenging when striving to achieve specific outcomes. This was especially the case for our client who needed 18 global Financial Institutions (each with their own internal policies and jurisdictional requirements) to discuss and agree on policy standards within a User Group.

The lack of consistency and structure throughout the governance and User Group management processes, meant that there was no audit history of policy changes, and no confidence that all member feedback had been considered and addressed. It was clear that the User Group meetings needed to be restructured to maximise efficiency, collaboration and outcomes, while ensuring members’ views were taken onboard and policy changes rationalised appropriately

Approach

Leveraging quality content and transparency

To facilitate effective and efficient policy meetings, preparation, quality content and transparency was critical. This depended on:

Involving the right participants – Our team confirmed that the correct participants from each institution were engaged with the KYC Registry User Group, and that the right representatives were involved, depending on the topic being discussed (Sanctions vs. Sustainability etc.).
Establishing the appropriate format – With a large number of members involved, it was essential that each member’s time was used wisely and that they were able to share feedback in a format which suited them best, whether it be via internal feedback loops, written or verbal feedback (on a 1:1 basis in some cases). We did this by allowing time for the review of documentation outside of meetings and ensuring the content of meetings was structured and collaborative. Throughout this process, BeyondFS also involved the development team who would be building these.

As a result, BeyondFS established a format and policy revision cycle which consisted of the following stages:

Potential changes/ gaps in policy identified on a bilateral basis by the User Group and by the BeyondFS Policy Lead conducting regulatory mapping exercises against the KYC Registry policy standards
Proposal of changes drafted and rationale shared with User Group for transparency and feedback
User Group members provided with a fixed timeframe to review changes
User Group policy calls to walk through the proposed changes and discuss changes. Bilateral calls were also held to to ensure all concerns were addressed.
User Group feedback reviewed, addressed and consolidated by BeyondFS Policy Lead
Final proposal shared with User Group, inclusive of rationales and addressing of feedback
Final proposal passed to development team for implementation

Outcome

An engaging and collaborative forum providing actionable feedback

By establishing an effective and efficient policy management cycle, BeyondFS helped our client to make comprehensive and necessary changes to its policy in a relatively short timeframe. We established an engaging and collaborative forum which leveraged the knowledge and experience of 18 global banks to ensure actionable feedback on policy changes, while confirming regulatory standards were met.